Anti-corruption and Whistleblower Protection Policy
1. Anti-corruption
Spectre’s reputation depends on how we conduct business. All employees, business partners and agents of our company must comply with all applicable laws and regulations in any location where we conduct business. Spectre operates in many countries, each of which has its own context regarding cultural and governance practices and norms. Therefore, it is important to have a common and clear anti-corruption policy across the various locations.
Integrity is one of Spectre’s core values, therefore all our work shall be conducted in an honest and ethical manner. Bribery and corruption actions are punishable for individuals and if Spectre is found to have taken part in them, we could face an unlimited fine and face irreparable damage to our reputation. We therefore take our legal responsibilities very seriously. We have zero tolerance for bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships.
2. Who must comply with this policy?
This policy applies to all individuals working at all levels including directors, managers, supervisors, employees, consultants, contractors, trainees, agents, or any other person associated with Spectre, wherever located.
This policy also applies to all forms of direct and indirect lobbying and political engagement. Spectre prohibits the use of bribery, facilitation payments, or undue influence to secure political or regulatory advantages. All lobbying positions, whether direct or via intermediary
Developed by: Group Responsible Business Director Jesper Ambrosius
Confirmed by: Responsible Business Committee
Changes: 29.10.2025
organizations, must be transparent, evidence-based, and aligned with Spectre’s Responsible Lobbying Policy
This policy does not form part of any employee’s contract of employment, and we may amend it at any time to further improve it.
3. What is bribery?
Bribery is a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit. Bribery includes offering, promising, giving, accepting or seeking a bribe.
Spectre does not make political contributions, donations, or payments to political parties, candidates, elected officials, or related organizations, either directly or indirectly through intermediaries. This prohibition includes financial contributions, in-kind support, or use of company resources for political purposes.
All forms of bribery are strictly prohibited. If you are unsure about whether a particular act constitutes bribery (e.g. whether an intended gift would be appropriate), consult with your direct manager or HR Manager or for employees in Denmark - with Group CFO.
Specifically, you must not:
➢ Give or offer any payment, gift, hospitality, or other benefit in the expectation that a business advantage will be received in return, or to reward any business received.
➢ Accept any offer from a third party that you know or suspect is made with the expectation that we will provide a business advantage for them or anyone else.
➢ Give or offer any payment (sometimes called a facilitation payment) to a government official in any country to facilitate or speed up a routine or necessary procedure.
➢ Threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.
4. Areas with exposure to corruption risks
Spectre is assessing intermediary organizations (e.g., industry associations) for alignment with our anti-corruption, integrity, and lobbying standards. We disclose memberships annually, including any contributions made, and disengage where serious misalignment exists. We have identified that certain activities create corruption risks for our company:
➢ All management position
➢ All HR personnel
➢ Import/export of goods including contact to customs authorities
➢ Supplier contacts/Purchasing duties
➢ Quality audits
➢ Social audits
➢ Environmental and any other audits
➢ Price negotiations with suppliers and customers
➢ Financial audits
Developed by: Group Responsible Business Director Jesper Ambrosius
Confirmed by: Responsible Business Committee
➢ Payments of invoices
➢ Payments to and contacts with tax authorities
➢ Salary payments
➢ Sales efforts aimed at customers
Changes: 29.10.2025
All employees in managerial positions, working in finance, supply chain, HR, quality and key account managers shall receive training on anti-corruption during onboarding entering any of named positions and when policy is revised. Employees and board members engaged in external representation, lobbying, or serving on boards of lobbying organizations will receive specific training on corruption risks in political and regulatory engagement
5. Conflict of interest
Our personal interests must not conflict with the interests of the company. We do not participate in business activities that compete with our company or are in a business relationship with our company, nor do we seek personal benefit from business relationships.
In case you find yourself in a situation where your interests are in conflict with company’s you are obligated to disclose that conflict to your superior.
6. Hospitality and gifts
This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships or maintaining Spectre’s image or reputation.
A gift or hospitality will not be appropriate if it is unduly lavish or could be seen as an inducement or reward for any preferential treatment (for example, during contractual negotiations or a tender process).
Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift. Gifts must not include cash or cash equivalent (such as vouchers) or be given in secret. Gifts must be given in the name of Spectre – not your own name.
Promotional gifts of low value such as Spectre merchandise may be given to our existing or potential suppliers and business partners and we can accept equivalent gifts from them.
Reasonable and appropriate gifts are:
➢ Not made with the intention of influencing a third party to obtain or retain business or a business advantage
➢ In compliance with the local law
➢ Given in Spectre’s name, not in your name
➢ Not including cash or equivalent
➢ Given openly, not secretly
➢ Appropriate in the circumstances (value of gift, time given/received etc.)
o Gifts for costumers’ employees may be of symbolic value only and adjusted to local circumstances. Further, the gift purchase must be agreed with the Sales Director who will define the level in the specific situation.
Developed by: Group Responsible Business Director Jesper Ambrosius
Confirmed by: Responsible Business Committee
Changes: 29.10.2025
o Gifts for companies at special occasions such as anniversaries etc. may be of higher value as they represent a marketing value for Spectre.
o Spectre employees can receive gifts of symbolic value and are expected to be shared within the team/department/company if possible.
You must declare all hospitality or gifts given to or received from colleagues, potential or existing customers or suppliers/subcontractors that are valued at least DKK 500. Gifts valued at least DKK 1000 must be approved by head of department. This does not apply to gifts given to an employee on behalf of Spectre. Gifts can be declared using a form on the company intranet.
You must also submit all expenses claims relating to hospitality, gifts, or payments to third parties in accordance with our expenses policy and record the reason for expenditure. All accounts, invoices, and other records relating to dealings with third parties including suppliers should be prepared with strict accuracy and completeness. Accounts must not be kept “offbook” to facilitate or conceal improper payments.
7. Responsibilities
You must:
➢ Ensure that you read, understand, and comply with this policy.
➢ Report if you believe or suspect that a conflict with this policy has occurred or may occur in the future.
➢ Report if you are offered a bribe by a third party, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of unlawful activity.
Any Spectre employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. Any non-employee who breaches this policy (or we have reasonable suspicion to believe this is the case) may have their contract terminated with immediate effect.
Group Responsible Business Director is responsible for the maintenance and implementation of this policy. Feedback on this policy can be discussed with the Group Responsible Business Director, as your feedback will be welcomed.
8. How to raise a concern?
If you are offered a bribe, or are asked to make one, or if you suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you must notify your manager or HR Manager or for employees in Denmark - Group CFO - as soon as possible. If for various reasons this is problematic, you shall follow the recommendations on whistleblowing.
9. Whistleblower protection
Spectre is committed to the highest possible standards of openness, honesty and accountability. We expect our employees, business partners and any stakeholders who have concerns about the company’s behavior to communicate those concerns to us.
Developed by: Group Responsible Business Director Jesper Ambrosius
Confirmed by: Responsible Business Committee Changes:
Employees are often the first to discover that there may be unlawful activities in a company, therefore they can be the first to inform those who address the problem. However, an employee may decide not to express these concerns because of feeling that speaking up would be disloyal to colleagues or the company. There may also be fear of reprisal. In these circumstances it may be easier to ignore the issue rather than report it.
The purpose of this policy is to encourage employees to report matters without the risk of victimization or discrimination. This policy enables employees to raise serious concerns they may have about matters occurring within or pertaining to Spectre, rather than overlooking a problem or seeking a resolution of the problem outside Spectre.
10. What is a whistleblower?
A whistleblower is a person who reports information on wrongdoing obtained in a work-related context. A whistleblower is encouraged to report instances where there are reasonable grounds to suspect misconduct or an improper state of affairs in any dealings concerning Spectre.
Wrongdoing may include but is not limited to:
➢ corruption and bribery,
➢ accounting fraud or misuse of finances,
➢ exploitative lobbying activities,
➢ breaches of product safety and compliance,
➢ breaches of protection of environment,
➢ breaches of protection of personal data,
➢ major breaches of occupational safety,
➢ other serious matters such as discrimination, violence or harassment.
11. Protection
Employees who refuse to accept or offer a bribe or those who raise concern or report another’s unlawful actions are sometimes worried about possible consequences. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We will ensure confidentiality of the person reporting and other people mentioned in the report and will not allow any kind of reprisal
12. Responsibilities
We expect everyone who works for Spectre to comply with our policies and procedures, professional standards, laws, and regulations. You also have a responsibility to speak up when you suspect something does not look or feel right.
The process for receiving and investigating whistleblower reports is outlined in the Whistleblowing and Grievances Process, which forms an integral part of this policy.
13. How to report?
In case you don’t feel safe reporting possible wrongdoing to your manager or HR manager, you should report the issue through the online form available on the company intranet for employees and on the Spectre website for external stakeholders. The form is anonymous with
Developed by: Group Responsible Business Director Jesper Ambrosius
Confirmed by: Responsible Business Committee
an option to give your name. Upon submission, you will receive a unique username and password. Please ensure you save these details, as they allow you to monitor the progress of your report and provide additional information if required.